The Standard
Vol. 4, Issue No. 18

It has already been a busy fall for the PBPA, which has included a recent submission of comments to the Railroad Commission of Texas, and there is still more to come. In this version of the Standard, we wanted to provide you with a copy of those comments, along with information on upcoming activities and events either in the Permian Basin or that could have impacts on operations in the region. As always, if you have any questions regarding the following, don't hesitate to let us know:

  • PBPA Comments to RRC
  • RRC: ERCOT Critical Load Designations
  • RRC: Pipeline Permitting Requirements
  • TCEQ: Emissions Inventory Workshop
  • Permian Basin MPO Survey
  • Texas Tech Screening of Fractured
  • Midland College PPDC Training Courses
  • PB Association of Pipeliners' Event
  • PRSC Stand Down for Road Safety Event


Ben Shepperd
PBPA in Action
On October 29, 2021, the PBPA submitted comment to the Railroad Commission of Texas (RRC) regarding proposed new 16 Texas Administrative Code (TAC) § 3.65 and § 3.107, relating to Critical Designation of Natural Gas Infrastructure. You can find a copy of these comments here. Thank you to those members on the PBPA Texas Legislative Committee, Regulatory Practices Committee and Electrical Coalition who helped PBPA develop these comments. If you have any questions about these comments or the continuing process the RRC and the Public Utility Commission of Texas (PUC) please contact Michael Lozano at
VIDEO: Reminder to File ERCOT Designation for Critical Loads Serving Natural Gas-Fired Electric Generation by November 1

As you know, the Electric Reliability Council of Texas (ERCOT) provides an application through which you may request your facility be designated as a “Critical Load Serving Natural Gas-Fired Electric Generation.” This designation is a critically important component of extreme weather preparedness.
The RRC urges all operators to review the Application for Critical Load Serving Electric Generation and Cogeneration and file, as appropriate, with your electric service provider(s). The application can be downloaded from the ERCOT website at
RRC previously issued a Notice to Operators in March 2021 asking operators to submit the application to their electric service provider(s). Earlier this month, RRC issued a notice asking operators to submit and update that information. On October 21, 2021 the RRC provided another notice reminder for operators to file the application(s) not later than November 1, 2021, so electric service providers can complete their seasonal extreme weather planning.
Questions regarding this application should be directed to your electric service provider. In addition, it is recommended that operators contact their electric service providers to verify designation of critical load status.
The RRC does not have jurisdiction over electric generation, electric transmission, or electric service providers. Related questions should be directed to the Public Utility Commission, ERCOT or your electric service providers. 
To view the video Reminder to File ERCOT Designation for Critical Loads Serving Natural Gas-Fired Electric Generation by November 1, visit the Railroad commission of Texas’ YouTube Channel at 6XZmRk
To view related notices to operators, visit the RRC website at

Notice to Pipeline Operators: On-Lease Pipelines Permitting Requirements - CORRECTION
The RRC requires production and flow lines to be permitted from the first point of measurement in accordance with 16 Texas Administrative Code (TAC) §3.70(a), effective January 6, 2020.
If before January 6, 2020, an operator removed the pipeline(s) from their active (or existing) permit because the pipeline(s) were on lease, the pipeline from the point of measurement from the well is required to be permitted. Please review all permits to determine if the pipelines are marked abandoned due to being on lease.
If the on-lease pipelines are currently transporting gas, operators must permit at the first point of measurement before the gas is commingled with gas from another well.
To file a new permit or maintain an existing permit in accordance with 16 TAC §3.70(a), operators must use the Pipeline Online Permitting System (POPS).
If you have any questions regarding this notice, please contact the Pipeline Safety Department at
Registration has begun for the Texas Commission on Environmental Quality (TCEQ) 2022 Emissions Inventory Workshop on January 27, 2022. There is no cost for participating in the online workshop.

Gain insight on estimating emissions from equipment leak fugitive emissions sources, learn to report emissions inventories online, and receive updates for the 2021 reporting year. During the event, a form will be provided for Professional Engineers and Professional Geoscientists to claim up to 3 hours of Continuing Education Credits. 

Registration is now open. Visit the Emissions Inventory Workshop webpage to learn more.
The Permian Basin Municipal Planning Organization (MPO) is conducting a study for a potential interregional corridor to provide freight and vehicular connectivity in and around the urbanized Midland-Odessa area and is seeking input.
Public Town Hall meetings were held September 20-21st, 2021 at the Hispanic Culture Center of Midland and Saulsbury Campus of Odessa College to discuss the project and seek public input. Presentation materials from those meetings and the survey are available online from the following links.
English and Spanish presentation
Permian Basin MPO Website Ongoing Studies | Permian Basin MPO
Permian Basin MPO Social Media 
The MPO wants to hear from PBPA members on the potential corridor. Please review the survey and provide your feedback to help with regional transportation issues.
Professor Bill Keffer and the Texas Tech Energy Law Program will be screening a movie by Mark Mathis called Fractured on Sunday, October 31, 2021, at Alamo Draft House in Lubbock, Texas. Doors open at 6:00 pm. The movie will run for one hour, from 6:30 to 7:30, and Mark will do a Q&A afterwards. Better yet, Admission is free! However, seating is limited.

If you're in Lubbock, and are interested in attending, please RSVP to Professor Keffer at
The Midland College Petroleum Professional Development Center (MC PPDC) provides quality training programs designed to keep oil and gas industry professionals current in their areas of expertise by offering the latest industry updates, as well as providing timely and pertinent educational opportunities. Click the below links for upcoming classes being offered by the MC PPDC in the coming months.
Registration Now Open for
2021 PRSC Stand Down for Road Safety Event

Today, the Permian Road Safety Coalition officially opened registration for its signature annual event, Stand Down for Road Safety, which will be held on Thursday, November 4 at the Bush Convention Center in Midland, Texas.
Additionally, the PRSC announced a special road safety training program, presented by the National Safety Council, which will take place immediately following Stand Down for Road Safety. More information on this training opportunity can be found in the article below.
A limited number of sponsorships, including the ever-popular expo booths, remain available. Both events are free of charge to attend though advance registration is required. Please use the buttons below to register or for additional information on sponsorships.